Until the end of September taxpayers may prepare for the invoice data disclosure

According to the information provided by NAV, the National Tax and Customs Board will not impose a default penalty under certain conditions if the taxpayer fails or does not properly fulfill the obligation to provide invoice data in the period between 1 July 2020 and 30 September 2020.

As previously reported, the rules of the Hungarian VAT Act on the obligation to provide invoice data information will change as of 1 July 2020:

• the previous value limit of HUF 100 thousand for the VAT content is abolished,
• data must be provided to NAV on any invoice issued by a taxable person to another domestic taxable person for a domestic transaction (other than an intra-Community supply of goods), irrespective of the VAT content of the invoice.
• there is also an obligation to provide information in respect of the invoices received if and when he exercises the right to deduct tax on the basis of the invoice received in his VAT return for the tax assessment period.

NAV will not impose any sanctions to those who do not or do not properly comply with their invoice data information obligations for the period from 1 July 2020 to 30 September 2020, given that the COVID-19 emergency significantly prevented taxpayers from complying with the new legal obligation, preparation.

This transition period may be an opportunity to complete the backward development of invoicing programs or, as NAV puts it, primarily for new obligors to download and familiarize themselves for example with NAV's free Online Billing program or otherwise organize their invoice data reporting obligations.

NAV will not penalize taxpayers who do not fully comply with the following obligations during the period specified above:

• provision of data on incoming invoices that do not reach the transferred tax of HUF 100,000,
• data provision on outgoing invoices that do not reach the transferred tax of HUF 100,000,
• the provision of invoice data within 4 days of the issue on manual invoices with a VAT content of HUF 100 thousand or more but less than HUF 500 thousand, if the data is provided within 5 days after the issue.

It is a very good news that according to the above, a taxable person who has already incurred an obligation to provide invoice data before 1 July 2020 is also exempted from the sanction with regard to the provision of data on invoices that do not reach the transferred VAT content of HUF 100,000.

However, it is important to emphasize that those who have not yet incurred an obligation to provide online account data will only be exempted from the penalty if they register in the NAV Online Account system at the latest by the date of issue of the first invoice (or document subject to an invoice: amendment, invalidation invoice).

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Should you have any questions regarding the contents of this newsletter or the actual IT implementation of the invoice data disclosure liability,
the tax expert colleagues and IT experts of VGD Hungary are at your disposal!